#audit
Independent audit and assurance engagements — SOC 2, financial statement audits, internal controls testing, evidence collection, and audit readiness for service organizations and growing businesses
Section 530 of the Revenue Act of 1978 blocks the IRS from assessing back payroll taxes on reclassified 1099 workers if a business proves reasonable basis, substantive consistency, and reporting consistency. Revenue Procedure 2025-10 now requires examiners to consider the relief first and sets 25% / 10-year thresholds for the industry-practice safe harbor.
Section 6751(b) requires a real IRS supervisor to personally approve penalties in writing before assessment. A working guide to using Chai, the Graev trilogy, and the December 2024 final regulations to defeat accuracy-related, fraud, and information-return penalties — which penalties qualify, what documents to demand, and how to raise the argument at Appeals before paying for Tax Court.
A practical guide for small businesses on identifying unclaimed property — uncashed vendor and payroll checks, customer credits, gift cards — applying state dormancy periods, mailing due diligence letters, and filing the NAUPA II holder report before Delaware or another state opens a contingency-fee audit.
Workers' compensation premium is recalculated every year using your actual payroll, and unprepared small employers routinely owe five-figure true-ups. This guide walks through the NCCI premium formula, the standard exception rules, the overtime carve-out math, owner and officer exclusion forms, the subcontractor COI rules that trigger the largest audit hits, and how to dispute a Final Audit Statement.
How acquirers execute a purchase price allocation under ASC 805 — identifying intangibles, handling bargain purchases and earn-out volatility, electing pushdown accounting, and reconciling the GAAP allocation to Form 8594 under Section 1060.
A practical guide to ASC 820 fair value measurements for private companies, funds, and CFOs—how to classify Level 1, 2, and 3 inputs, build defensible Level 3 valuations for private equity stakes and earn-outs, write disclosures auditors accept, and survive scrutiny of unobservable assumptions.
A working guide to California AB5, the three-prong ABC test, the Borello and business-to-business exemptions, and EDD audit exposure that can reach $25,000 per willful misclassification — plus a practical compliance workflow for small businesses.
A practitioner's walkthrough of Circular 230—Sections 10.22, 10.29, 10.34, 10.36, 10.37, and 10.51—covering conflicts of interest, return-position standards, written-advice hygiene, and how OPR investigations actually proceed.
How willful non-filers, crypto whales, and offshore account holders use IRS Form 14457 to trade criminal exposure for a defined six-year civil resolution under the Voluntary Disclosure Practice — including the December 2025 proposed framework, disqualifying traps, and when to choose Streamlined or DIIRSP instead.
Schedule B-1 of Form 1065 uses Section 267(c) attribution — not Section 318 — to identify partners who own 50% or more of profit, loss, or capital. A practical guide for tiered partnerships, family holding LLCs, and private equity fund structures.
Section 1446(f) requires buyers of partnership interests to withhold 10% of the amount realized when a foreign partner sells and remit it to the IRS within 20 days on Form 8288. This guide walks through the six exceptions, the certifications that must be in hand before closing, and the bookkeeping records that defend the position under audit.
Section 7463 lets a taxpayer challenge an IRS deficiency of $50,000 or less in U.S. Tax Court without a lawyer for a $60 filing fee, using a simplified Form 2 petition and informal trial — in exchange for giving up the right to appeal and the ability to set precedent.
